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令人惊讶 is a curious and fairly common phrase, e.g.:

关于人体令人惊讶的事实 (source)
About [关于] human body [人体] surprising [令人惊讶] facts [事实]

I'm wondering if using 令人惊讶 requires that people have actually been surprised by whatever is being referred to.

Question: Does 令人惊讶 require that someone actually be surprised?

As opposed to hypothetically making someone surprised were they to be made aware (based on the author's judgement).

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Does 令人惊讶 require that someone actually be surprised?

No. Just like "surprising", it is used to describe unexpected or unusual things/facts, which may have a potential to make someone surprised.

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It would be clear to you if you take 令人惊讶的事实 as the fact that makes people surprised.

It just works like attributive clause/phrase in English.

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Some people use this way, although I don't like it personally.

As I read it. I think it can be click bait if I don't feel that it is surprising. Some news title really have tendency to use some word that catch people attention. For example something like this 萬人看傻了眼. You can find a lot of news title include "萬人看傻了眼" or something like that. Some editors will put some words on news title regardless of whether or not actually so many people experience shock or not. In this example, If I feel the news is boring ,I may feel that it is click bait.

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